The inspectors identified a
NCV of
10 CFR 50.59(d)(1) for the licensees failure to document an evaluation that provided a basis for the determination that the change, test, or experiment did not require a license amendment. Specifically, for Special Test Procedure SPP-07-002, Test of 1B
DG Voltage Regulator Following Maintenance Via
SX Pump Start, the licensee failed to provide an evaluation as to why disconnecting the offsite electrical power feed to the emergency bus during power operation with an inoperable diesel generator did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a structure system or component important to safety previously evaluated in the
Updated Final Safety Analysis Report. The licensee entered the appropriate limiting condition of operation for the offsite power circuit during the test, entered this issue into the corrective action program, and initiated actions to complete a
10 CFR 50.59 evaluation to determine if these procedure changes were acceptable without a license amendment. The primary cause of this issue was related to the cross-cutting area of Human Performance for failure to use conservative assumptions in decision making and to adopt a requirement that demonstrates the proposed action is safe in order to proceed (
H.1(b)). Because the issue potentially impacted the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the special test procedure, that affected the
Updated Final Safety Analysis Report described design function of equipment important to safety, would not have ultimately required NRC prior approval. Based upon the Phase 1 screening, the inspectors concluded that the issue was of very low safety significance
